PTAB

IPR2018-00859

Bestway USA Inc v. Team Worldwide Corp

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Inflatable Airbed Provided With Electric Pump Having Pump Body Recessed Into The Inflatable Airbed
  • Brief Description: The ’018 patent is directed to inflatable products, such as airbeds, that include a built-in electric pump. The key feature is that the pump body is permanently mounted in the exterior wall and is at least partially recessed into the inflatable body to create a more compact and integrated design.

3. Grounds for Unpatentability

Ground 1: Anticipation over Chaffee - Claims 1, 7, 11-14 are anticipated under 35 U.S.C. §102 by Chaffee.

  • Prior Art Relied Upon: Chaffee (Patent 7,039,972).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chaffee disclosed every limitation of the challenged claims. Chaffee teaches an inflatable mattress with a built-in "fluid controller" (an electric pump). Petitioner asserted that Chaffee’s pump housing is built into the exterior wall of the inflatable bladder, is partially recessed within it (leaving a portion exposed), and is permanently held by being "adhered or sealed" to the bladder. Chaffee also disclosed powering the pump via standard house current (AC power, claim 11) using an outlet plug (a connector, claim 7) and positioning the pump and its air outlet within the inflatable body (claims 12-13).

Ground 2: Anticipation over Chan - Claims 1, 7, 12-14 are anticipated under 35 U.S.C. §102 by Chan.

  • Prior Art Relied Upon: Chan (Patent 5,564,963).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Chan, which discloses a self-generated air-cushion toy, anticipated the claims. Chan’s "pillow" is an inflatable body, and its fan and motor assembly (the electric pump) are located within the pillow. Petitioner argued the pump housing is built into the pillow’s exterior wall, is recessed into it, and is permanently secured by a frame and pegs. A portion of the pump body is exposed through perforations in the pillow walls. Chan’s pump is battery-powered and connected via a switch (a connector, claim 7), and both the pump body and its air outlets are located within the inflatable pillow (claims 12-13).

Ground 3: Obviousness over Parienti and Goldsmith - Claims 1, 7, 11-14 are obvious over Parienti in view of Goldsmith.

  • Prior Art Relied Upon: Parienti (Patent 6,018,960), Goldsmith (Patent 2,493,067).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted Parienti disclosed an inflatable mattress with an electric pump built into its exterior wall via gluing, but did not explicitly teach recessing the pump into the mattress. Goldsmith disclosed a mattress with a blower unit housed in a casing that is arranged within and at one end of the mattress, i.e., recessed.
    • Motivation to Combine: A POSITA would combine these references to improve the product's spatial efficiency and durability. Recessing Parienti’s externally-mounted pump, as taught by Goldsmith, would create a more compact design, reduce the pump's external bulge for user comfort, and protect the pump from damage, all of which were well-known benefits of recessed designs in the art. For claim 11 (AC power), Petitioner argued it would have been obvious to add an AC power option (taught by Goldsmith) to Parienti’s solar-powered pump to provide a backup or alternative power source.
    • Expectation of Success: A POSITA would have had a high expectation of success, as recessing a pump into an inflatable body was a known design choice with predictable results.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Chaffee with Walker (Patent 4,890,344) to add a rectifier for AC-to-DC power conversion (claim 5); combining Chan with Walker for the same reason (claims 5 and 11); and combining Parienti, Goldsmith, and Walker (claim 5). An alternative obviousness ground was also asserted over Chaffee alone.

4. Key Claim Construction Positions

  • "inflatable body": Petitioner argued that the Broadest Reasonable Interpretation (BRI) of this term is "a structure that expands when filled with air or other gases." This construction was central to the anticipation argument over Chan, whose inflatable pillow has perforations. Petitioner contended that the Patent Owner’s proposed additional requirement that the body be "substantially airtight" was improper because the term is not used in the patent, the specification does not provide a clear definition supporting it, and prior art shows that even perforated structures are considered "inflatable."
  • "built into": For the purposes of the petition, Petitioner adopted the construction proposed by the Patent Owner and construed by the district court in related litigation: something "is not readily removed without changing its character" or is "integrated and not detachable."

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 5, 7, and 11-14 of the ’018 patent as unpatentable.